EB Comment Period 1-Responses edits
Description
Responses to Public Comments Received on First Coment Draft of LEED-EB Comment Period was Open: 03/01/04 - 03/30/04)Document Date: June10, 2004Proposed Changes to Issue Language Date Type of Category Comment # Credit Likes and Dislikes Ways To Improve Responses LEED-EB for Second Summaries Changes Submitted ChangeComment DraftPage #3 Building Operating Prerequisite The option of providing 3 months of data is only available to Add this clarification to the ClarificationData Comment: Allowing a submission project teams seeking initial LEED-EB certification. In instances text of introduction to LEED-based on only 3 months of data seems where certifications are granted to buildings based on less than EBLength of odd, as this will not allow for seasonal Require some sort one years worth of data, applicants are required to prorate the required N/A swings in energy consumption. It also of weather data approximating a full year using the portion of the usage that performance (General General Gen-Com1 would seem that if this data is to be used Require a 12 month data period documentation for 3/1/2004 occurs in the months reported. Subsequent re-certifications period for first LEED-EB as a base line you would need some the data year require performance results for the whole performance period certification Comments)weather information to determine if the provided.(the period of time since the previous certification).under LEED-EBdata for that year might be ...
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| Publié par | Uslio |
| Nombre de lectures | 64 |
| Langue | English |
Extrait
Responses to Public Comments Received on First Coment Draft of LEED-EB
Comment Period was Open: 03/01/04 - 03/30/04)
Document Date: June10, 2004
Category
Comment #
Issue
Summaries
Credit
Likes and Dislikes
Ways To Improve
Language
Changes
Date
Submitted
Responses
Proposed Changes to
LEED-EB for Second
Comment Draft
Type of
Change
General
Gen-Com1
Length of
required
performance
period for first
certification
under LEED-EB
N/A
(General
LEED-EB
Comments)
Page #3 Building Operating Prerequisite
Data Comment: Allowing a submission
based on only 3 months of data seems
odd, as this will not allow for seasonal
swings in energy consumption. It also
would seem that if this data is to be used
as a base line you would need some
weather information to determine if the
data for that year might be skewed
because it was an unseasonably cold or
hot year
Require a 12 month data period
Require some sort
of weather
documentation for
the data year
provided.
3/1/2004
The option of providing 3 months of data is only available to
project teams seeking initial LEED-EB certification. In instances
where certifications are granted to buildings based on less than
one years worth of data, applicants are required to prorate the
data approximating a full year using the portion of the usage that
occurs in the months reported. Subsequent re-certifications
require performance results for the whole performance period
(the period of time since the previous certification).
Add this clarification to the
text of introduction to LEED-
EB
Clarification
General
Gen-Com2
Create separate
organizational
category for
addressing
hazardous
materials
N/A
(General
LEED-EB
Comments)
This is a general organizational
comment. I feel very strongly that for
EXISTING Buildings, it is fundamental to
reorganize the basic categories at the
highest level.
In addition to SS, WE, E&A,
M&R, IEQ and Innovation, there
should be a SEVENTH subject:
MITIGATION OF HAZARDOUS
MATERIALS. This entire
category should be a pre-
requisite. All aspects of the other
6 categories, pertaining to
removal of hazardous materials,
should be folded into the
category, instead.
"It is fundamental to
the concept of
Green/Sustainable
Design, that all
hazardous materials
be removed from an
existing building and
site, prior to either
general work forces
or occupants being
on-site. Therefore,
all 'credits' in this
category are 'pre-
requisites'." etc.
3/1/2004
No Action
None
General
Gen-Com3
Quarterly
Reports
N/A
(General
LEED-EB
Comments)
Great concept and the draft is really
pretty good. Just a few general
thoughts. 1. Paper/time intensive due to
quarterly record keeping/submission
requirements. 2. Will be expensive to
submit and maintain - may scare
candidates away.
-
-
3/1/2004
Quarterly reporting addresses two important sustainability issues:
1. Tracking of ongoing performance so that performance
degradation is promptly identified so it can be corrected
2. Supporting the institutional commitment needed to ensure
sustainability actions are maintained successfully over the long
term.
Periodic consultation with the individuals responsible for
successful achievement of credits and prerequisites and the
people affected helps ensure that activities meant to reduce the
environmental footprint of a building continue to occur. An
electronic template for quarterly reporting will be provided to
users of the post pilot versions of LEED-EB initially in spreadsheet
form and eventually online.
Provide LEED-EB users with
a template for tracking
quarterly performance.
Include in
supporting
materials for
LEED-EB
users
General
Gen-Com4
Congratulations
N/A
(General
LEED-EB
Comments)
Over all.. very well though out - the staff
at USGBC and committee should be
Congratulated. Thanks for your hard
work. I think the standard is the best
possible and will help improve buildings
through out the US
see above
see above
3/1/2004
OK
No Action
None
General
Gen-Com5
Application to
Historic Buildings
N/A
(General
LEED-EB
Comments)
The rating system doesn't make
provision for the cultural value of historic
buildings. I fear that the LEED rating
system will be just one more reason to
threaten historic properties and/or their
character defining features (roofs,
exterior finish materials, windows, doors)
and significant interior spaces.
Create a category for historically
significant buildings. Provide a
significant number of points for
projects that preserve, restore or
rehabilitate historic buildings.
The LEED rating system doesn't
appear to recognize the
significance of historic buildings,
structures and landscapes.
A significant number
of additional points
should be awarded
for the appropriate
rehabilitation of
historic buildings.
Not just because of
the embodied
energy they
represent, but also
because of their
ability to
communicate
information to future
generations that
modern buildings
cannot. Consult with
the National Park
Service to establish
meaningful
language to be
included.
3/1/2004
Improving O&M practices and promoting the preservation and
reuse of existing buildings are fundamental tenets of LEED-EB.
As such, LEED-EB is expected to work very well for historic
buildings. The flexibility of the LEED-EB point system provides
project teams who must be sensitive to historic preservation
concerns many avenues for success. The performance based
(rather than prescriptive) structure of most LEED-EB credits also
enables project teams to succeed and remain sensitive to historic
preservation issues. The LEED-EB committee has reviewed The
Secretary of the Interior's Standards for Treatment of Historic
Properties. The Secretary of the Interior's Standards for
Treatment of Historic Properties apply to all structures under the
control of the Department of the Interior, which include the
National Park Service Buildings. No specific conflicts with LEED-
EB have been identified. An appendix dealing with historic
buildings will be added to the LEED-EB Reference Guide.
No Change
None
General
Gen-Com6
Name of LEED-
EB
N/A
(General
LEED-EB
Comments)
It has been suggested that LEED-EB
should be renamed to LEED-OM to
address the fact that it places such
heavy emphasis on Operating &
Maintenance Procedures and that it is
other wise confused with many
renovation projects. We recently had a
situation where LEED-NC was accepted
as a standard for new buildings and
LEED-EB as a standard for existing
buildings (regardless of the scope of the
renovation) in a US Government SFO.
This resulted in a very apples-to-
oranges comparison among projects
that submitted proposals using either
system.
Please consider revising to
LEED for Operations and
Maintenance (LEED-OM).
See above.
3/1/2004
LEED-EB addresses the operations and upgrades of existing
buildings, as such the name, which has been in use since its
inception, appropriately conveys this scope. In general, if the
project scope is a complete gut rehab or greater, project teams
should use the LEED-NC Rating System.
Clarify scope of LEED-EB
Clarification
General
Gen-Com7
Points Don’t Add
Up Right
N/A
(General
LEED-EB
Comments)
Page 12 of the draft states that there are
78 possible base points plus 5 IOU.
Adding up all the sections shows 77
base points.
correct the numbers
correct the numbers
3/1/2004
The LEED-EB MR Credit for waste management has 2 points and
as a result the total points is 83.
Correct points for MR -
Waste Management credit
through out document.
Editorial
General
Gen-Com8
Length of
required
performance
period for first
certification
under LEED-EB
N/A
(General
LEED-EB
Comments)
1. Page 3 "Building Operating
Performance Data" has a
statement about being able to
get initial certification with 3
months of data. I believe this
should be clarified, for example
several of the EA credits call for
12 months of utility bills and
annual data. Does the statement
on page 3 override the 12 month
or annual requirement? Judging
building energy performance
doesn't make sense on 3
months of data, so I assume this
is not the intent. I think each
credit should explicitly say where
it is acceptable to provide 3
months of data for initial
certification. 2. Statement /
description of overall structure of
the credits (e.g. Intent,
Requirement, etc.) and what the
sections are would be helpful
(similar to that used in NC
reference guide.)
3/1/2004
See Response to General Comment 1
See Response to General
Comment 1
See
Response to
General
Comment 1
General
Gen-Com9
Features that
reduce solid
waste from
churn
N/A
(General
LEED-EB
Comments)
The current LEED rating systems give
credits and points for activities that have
prevented harm to the environment in
the Materials and Resources section.
Use of recycled product, for example.
However, credits and points have not
been available for actions that will
prevent future harm.
it is proposed that an additional
credit be given for upgrades that
result in the installation of
reusable building elements, in
particular, walls and floors. This
will incent building managers to
look at solutions that are
reusable, but with slightly higher
first cost than single use
technologies.
Credit X.X 1 Point
Demountable Walls
and Raised Modular
Flooring Intent
Encourage the use
of renewable or
relocatable
technologies in
areas that are likely
to be torn down and
rebuilt multiple times
during the tenancy
of the building. Aside
from reducing the
environmental
impact caused by
tearing down and
putting up semi-
permanent
structures, ease or
reconfiguration can
be translated into
reduced unusable
and unused floor
spaces over time.
Requirements At
least 40% of the
total linear footage
of all interior office
walls to be
constructed from
demountable
elocatable wall
3/1/2004
Rather than adopt a regulatory/prescriptive approach to
environmental performance, LEED-EB, where practical, sets
performance benchmarks allowing project teams to demonstrate
credit/prerequisite achievement in numerous ways. Keeping
environmental goals in mind but allowing building owners,
managers and competition in the market to identify increasingly
cost effective ways to achieve these goals has been and will
continue to be a driving force behind the development of LEED-
EB. Reusable walls and raised flooring are ways to reduce solid
waste, lower costs and to reduce the use of new resources
associated with churn. While no specific credit will be inserted into
the LEED-EB Rating System, the use of these technologies help
project teams demonstrate compliance with performance goals
associated with solid waste reduction and material reuse credits
No Change
None
General
Gen-Com10
Application to
Historic Buildings
N/A
(General
LEED-EB
Comments)
We are concerned that the standards
may result in the loss of historic and
cultural resources as a result of
application of the proposed LEED-EB
standards. LEED standards should
embrace historic preservation as a goal
that may compliment and enhance
sustainability efforts. I foresee particular
danger for loss or damage to resources
in institutional settings.
At key points in the EB Rating
System, it is very important to
ask those using the system to
consider the possible loss of
historic or cultural resources.
Rather than further an already
complicated system (EB, LE, IC,
and so on), why not have
prerequisites throughout the
system requiring the
consideration of such resources.
If historic resources are
encountered at these points,
different (or modified) standards
for certain requirements would
be enabled.
Refer to The
Secretary of the
Interior's Standards
for Rehabilitation
and Treatment of
Historic Properties.
3/1/2004
See response to General Comment 5.
No Change
None
General
Gen-Com11
Recertification
role of LEED-EB
N/A
(General
LEED-EB
Comments)
This comment is about the section titled
"How Often Re-Certification under
LEED for Existing Buildings Is
Required", which is on page 3. This
section does not explain when a building
originally certified under LEED for New
Construction should switch over to
existing building certification.
Please add a sentence here
explaining that buildings must be
5 years old to be certified under
LEED EB and that buildings
originally certified under LEED
New Construction must switch to
Existing Building certification
after 5 years. These two very
important points are made
(separated by a lot of other
verbiage) later in the
introduction, but it's confusing. If
you just state it up front, it will be
easier on the readers.
This is just a
recommended
change to make it
easier to understand
the intent of the
rating system.
3/1/2004
LEED-EB is a certification and re-certification tool for all buildings
including buildings originally certified under LEED-NC. The
description of LEED-EB will be changed to clearly explain that
LEED-EB can be used to re-certify buildings originally certified
under LEED-NC and those originally certified under LEED-EB.
Explain more clearly in the
introduction that LEED-EB is
the re-certification vehicle for
all buildings including both
buildings originally certified
under LEED-NC and under
LEED-EB.
Editorial
General
Gen-Com12
Recertification
role of LEED-EB
N/A
(General
LEED-EB
Comments)
In the section termed "How Often re-
certification Under LEED-EB is
Required", there are a couple of items
to consider. First, when the owner is on
a 5-year re-certification program, how
does one know the building is
functioning as intended other than the
owner? As with ISO and UL standards -
compliance reports, a third party audit is
done to confirm the system still
conforms as registered. I do not note in
the standard an ongoing monitoring
system for the program. Re-certification
can occur as the owner wants to or at a
minimum of once every 5 years. What
happens when the owner for whatever
reason makes a major modification to
the building? Re-certification should be
required at those points in time as well.
Add wording that requires third
party auditing when the
recertification process is to occur
on a time frame greater than
one year. This audit could be
conducted by USGBC or by an
outside organization. Those that
re-certify every year would be
exempted from this. Major
modifications to the building
should trigger a re-certification.
Add wording that
states, "When re-
certification is done
on cycles greater
than one year, the
EB program for the
building is to be
audited by an
independent third
part to verify the
building is
conforming to the
requirements." "
When a major
maintenance
program, building
update, modification,
or change in use
happens with the
building, the owner
is to initiate the Re-
certification Process
within six months of
the completion of
the work."
3/1/2004
A building which has been certified under LEED-EB must submit
performance data covering the entire period of performance since
any previous certification or re-certification. The period of
performance is defined as the interval of time between LEED-EB
certification reviews. Upgrades of building systems are captured
in ongoing performance data.
No Change
None
General
Gen-Com13
Historic Buildings
N/A
(General
LEED-EB
Comments)
I fully support the sustainable use of
new, renovated and existing buildings.
Continual use of the embodied energy in
the existing infrastructure is inherently
sustainable. However, I don't see any
mention or reference to the specific
requirements of adaptive re-use of
historic buildings in the LEED
documents. Unfortunately I was not
aware of the review period for LEED-
NC, and I understand that major
renovation is considered for LEED credit
under LEED-NC, so my comments may
apply to that document as well. I hope
the following thoughts are helpful and
useful.
The LEED-EB could be
improved by addressing historic
buildings, at least in the general
guidance of the document.
There is a natural overlap and
connections between LEED
activities and historic
preservation activities. There are
very distinct technical
requirements for both. Has
LEED been tested on historic
projects? If so, with what kind of
results? If not, should it be? Are
cautionary comments desirable
for the project manager to be
aware of potential conflicts
between LEED requirements
and preservation principles or
specific project requirements for
the preservation incentives? Etc.
Could there be a type of historic
preservation credit in LEED-NC
and LEED-EB?
There could be a
sentence added in
the instructions or
introduction
addressing
sustainable historic
preservation, such
as: "Reuse of
existing buildings
and infrastructure is
a sustainable
activity, taking
advantage of the
embodied energy in
the structure. LEED
rating is inherently
compatible with the
preservation of
historic structures.
Using the LEED
rating system for
historic projects can
be a complementary
process to assure
preservation of both
heritage values and
the environment."
There could also be
cautions regarding
the toxicity of some
preservation
products and
ethods and that
3/1/2004
An appendix dealing with historic buildings will be added to the
LEED-EB Reference Guide.
Make proposed editorial
changes
Editorial
General
Gen-Com14
LEED-EB
Development
Process
N/A
(General
LEED-EB
Comments)
LEED EB was not developed in a non-
consensus process There are a number
of credits or prerequisites that lack
technical rigor and/or a scientific basis
(please see comments elsewhere)
The LEED-EB development
committee membership should
be balanced among interested
parties To assure LEED-EB
incorporates a sound and widely-
recognized scientific basis, it
should be subject to a nationally
recognized consensus process,
such as ANSI
USGBC should not
promote LEED-EB
as a document
developed in a
consensus-like
manner
3/1/2004
The public comment process used for LEED Rating Systems is
open to both USGBC and non-members of the USGBC. The
LEED-EB Committee has used the process described in the
LEED Foundations Document to develop the LEED-EB Rating
System.
The USGBC process for development of LEED Rating Systems
has been designed to be transparent and consensus based. The
multiple public comment periods which precede the ultimate
balloting of a LEED product are open to both USGBC members
and non-members. The LEED development process is detailed
in the LEED Foundations document which is available for review
on the USGBC Website
(http://www.usgbc.org/LEED/LEED_main.asp). The USGBC
consensus and balloting processed are available for review on the
USGBC Website (http://www.usgbc.org/AboutUs/consensus.asp).
No Change
None
General
Gen-Com15
Certified Wood
Requirement
N/A
(General
LEED-EB
Comments)
LEED should recognize the Sustainable
Forestry Initiative for forest products.
LEED should recognize the
Sustainable Forestry Initiative for
forest products.
LEED should
recognize the
Sustainable Forestry
Initiative for forest
products.
3/1/2004
No conclusive study establishing equivalence between the FSC
wood certification program (the standard currently recognized in
all LEED products) and the SFI wood certification standard has
been approved by the USGBC as of this date.
No Change
None
General
Gen-Com16
Multi-Tenant
Existing Buildings
N/A
(General
LEED-EB
Comments)
The requirements parallel very well
those associated with the LEED NC and
thus are meaningful to the marketplace.
There is something missing in
that the emphasis will result in
OWNER OCCUPIED building
being very good candidates.
How much of the market is that
portion that is TENANT
OCCUPIED? A developer faced
with this type of performance for
and EB building will be hard
pressed to have the tenants
provide this kind of action Yes , it
has been done by one developer
for a new building in an industrial
park in Kansas City. He made
the commitment and is requiring
the tenants to also comply. the
degree of success is still out on
this project, according the words
heard in the "Heartland
Conference".
The pricing of rental
or leased property
must address this
concept in order for
a tenant to step on
the bandwagon. The
best way of doing
this might be in the
emphasis on the
"energy and
atmosphere" portion
of the requirements.
They are adequately
addressed but how
to motivate a
developer to step up
and motivate the
marketplace. Tough
question. Maybe the
cost of and
availability of energy
will be the motivator.
3/1/2004
Multi-tenant existing buildings will be addressed with an
application guide in the future. The development of market
specific application guides follows the established LEED protocols
to address multiple vertical market sectors such as healthcare
facilities, laboratories, schools, etc.
No Change
None
General
Gen-Com17
Water Efficiency
N/A
(General
LEED-EB
Comments)
I believe that having less than 10% of
the credit points related to water does
not value this critical resource at an
appropriate level. Water is the one most
important resource for the sustainable
future of the world.
More points should be given for
sustainable water use and
sustainable water resource
management.
See comments
related to specific
water efficiency
credits.
3/1/2004
As with LEED-NC, many LEED-EB credits, while divided into the
five general LEED categories, have synergies and design
considerations that span multiple categories. This is particularly
true for the WE category as multiple ‘water related’ credits exist in
the SS category. Review of credit weightings will be a
fundamental part of the LEED v3 update.
No Change
None
General
Gen-Com18
LEED-EB
Development
Process
N/A
(General
LEED-EB
Comments)
In conjunction with other members of
the North American Coalition on Green
Building, CPA has the following general
comments: 1)The open comment period
associated with this document is
commendable. That said, 2)LEED-EB
was not developed in a non-consensus
process 3)Materially affected parties
have not been permitted to participate in
the development of the standard.
4)There are a number of specific credits
where the technical rigor could be
improved. Please see our comments
elsewhere in the record.
1) The LEED-EB development
committee membership should
be balanced between interested
parties. 2) To assure LEED-EB
incorporates a sound and widely-
recognized scientific basis, it
should be subject to a nationally
recognized consensus process,
such as ANSI. 3) How USGBC
chooses to resolve the
comments received will be the
true test of due process. 4) A
true consensus process assures
that interested parties are
provided with all comments
submitted and, further, are given
the opportunity to support other's
comments. 5) The final
recommendation on whether a
comment is incorporated into
LEED-EB should be
accomplished through a ballot of
balanced interests, thus
representing a consensus
viewpoint of all those who are
materially affected.
1)USGBC should
not promote LEED-
EB as a document
developed in a
consensus like
manner. 2)USGBC
should make a
statement that these
provisions represent
the viewpoints of
USGBC members.
3/1/2004
Please see response to General Comment 14.
No Change
None
General
Gen-Com19
Length of
Performance
Period
N/A
(General
LEED-EB
Comments)
Page 3 - Building Operating
Performance Data This paragraph
seems to indicate that one year of
building operating performance data is
needed, however, many of the actual
credits require 5 years of historical data.
The 5 years of data seems overly
burdensome. Either way, the amount of
historical data required should be
coordinated.
N/A
N/A
3/1/2004
See response to General Comment number 1.
No Change
None
General
Gen-Com20
LEED-EB
Process for
Building Owners
N/A
(General
LEED-EB
Comments)
The introduction provides no instruction
on how to work through the certification
process.
It is important for participants to
know how to enter a building into
the LEED process, and what will
be required and what to expect
along the path to certification. If
we make it easier and more
clear to users, they will be more
likely to use the product. See
below for sample wording.
LEED-EB Rating
Process and Scoring
In order for the
USGBC to certify
your building, the
following process
must be followed:
Contact the USGBC
to enter your
building into the
LEED-EB rating
process. An entry
fee will be required.
A personal web
access account will
be set up for you to
obtain a complete
copy of the rating
system, rating tools,
the Reference
Guide, and Project
Checklist. Use the
Project Checklist at
any time to gauge
the status or
progress of your
building project. Use
of a LEED-
Accredited
Professional is
highly
recommended for
rganizing your
3/1/2004
An explanation of the LEED-EB certification process will be added
to the LEED-EB introduction and the USGBC Web site will be
updated.
An explanation along the
lines of the proposed
language will be added to the
LEED-EB introduction.
Editorial
General
Gen-Com21
Surrounding
Area
Improvements
N/A
(General
LEED-EB
Comments)
The environmental performance, or
“green-ness,” of a building is as much a
function of how it relates to surroundings
in the built and natural environment as it
is materials. We recognize that most
developers have only control over
individual project sites, and in many
cases, these are small parcels of land.
Their ability to increase the
environmental performance may hinge
on zoning, planning and transportation
decisions that are out of their control or
resistant to change. We applaud
U.S.G.B.C.’s efforts to both educate and
bring more recognition to an entire
range of decisions that produce better
development. As the number of
localities incorporating the LEED
scorecards into development decisions
grows, it is increasingly important to
offer tools that result in improved
performance across a range of building
contexts. As such, some of our
comments included "NOTES" to bring
consideration of context into the credit or
pre-requisite. For example, localities
seeking to redirect development towards
transit districts may find some of the
alternative transportation credits highly us
Addressed above.
There could be
language for
developers who
agree to upgrade
and repair existing
gray infrastructure.
While this would be
a first, older cities
that have failing
sewers and water
lines are not likely to
benefit from
infiltration and green
infrastructure.
Language to allow
credit to developers
who upgrade or
repair failing
sewer/water lines in
proximity to their
buildings (within 500
feet)would be
environmentally
helpful.
3/1/2004
This concept could be proposed in individual project applications
as an innovation credit. This improvement may only be available
to a few existing buildings owners and as such is not appropriate
as a specific credit or point in LEED-EB.
No Change
Put on list to
address in
future
General
Gen-Com22
Template for
Quarterly
Reports
N/A
(General
LEED-EB
Comments)
The amount of paperwork to prepare for
a LEED-NC or LEED-EB submission
can be considered by some to be
overwhelming. It is my understanding
that LEED-EB is currently developing a
spreadsheet for LEED-EB to track
inspections and so forth for various
credits.
We suggest that wording be
incorporated into the
introduction/overview and
perhaps elsewhere of LEED-EB
that notifies prospective users
that these resources are
available and where to find
them. Hopefully this will help
alleviate some of the
tentativeness experienced by
first time and prospective users.
(see above)
3/1/2004
A clarification of the documentation requirements will be added to
the LEED-EB introduction.
A clarification of the
documentation requirements
will be added to the LEED-
EB introduction.
Clarification
General
Gen-Com23
Building
Occupant
Surveys
N/A
(General
LEED-EB
Comments)
NOTE: These comments apply to the
Indoor Environmental Quality category.
Existing credits within the IEQ category
(4.1, 4.2, 5.3, 5.4, 6.1, 6.2, 7.1, 7.2, 8.1-
2, and 8.3-4) require submittals
demonstrating that certain objective
criteria have been met. While it is indeed
essential to conduct physical
measurements of building performance,
studies have shown that it is also useful
to acquire occupant perceptions of
comfort and productivity in order to learn
how buildings are truly performing from
the standpoint of the people who use
them. We propose a new credit in the
Indoor Environmental Quality category,
IEQ credit 10: Occupant POE survey.
Alternatively, we propose that submittals
for credits 4.1, 4.2, 5.3, 5.4, 6.1, 6.2, 7.1,
7.2, 8.1-2, and 8.3-4 be satisfied with
completion of a survey. Please see our
comments on those individual credits
also.
POE surveys are an important
way of providing feedback to the
participants in the building
industry. Survey results can be
used as diagnostic information
for identifying specific problems
in a building or for longer-term
goals such as providing
feedback to designers (Zimring
2001; Leaman 2003).
Occupants’ opinions give us
important information about how
a building is actually performing
from the perspective of those
who use the building. As noted
by the U.S. Federal Facilities
Council (2001), POE “is based
on the idea that better living
space can be designed by
asking users about their needs.”
Further, the Probe studies in the
UK have shown that a direct
relationship exists between
worker comfort and self-
reported health and productivity
(Leaman 2000). Web-based
surveys can quickly and
inexpensively collect these
opinions and display the results.
Drill-down questions and open-
ended comment fields allow
diagnoses of building problems
be performed An example of
IEQ credit 10
Occupant POE
survey Intent:
Provide comfortable
Indoor
Environmental
Quality that
enhances the
building occupants’
well-being and
productivity by
obtaining their
opinion and
feedback.
Requirements:
Conduct a LEED-
approved occupant
POE survey that
addresses the IEQ
section categories
(Thermal comfort,
Air quality, lighting
and views,
Acoustics, Cleaning)
to collect occupant
comfort opinions
and productivity
impacts through self
assessed
productivity
measures. Potential
Technologies &
trategies: Improve
3/1/2004
The addition of a building occupant engagement credit will be
considered in the future for an update of LEED-EB
No Change
None
General
Gen-Com24
Congratulations
N/A
(General
LEED-EB
Comments)
Congratulation to the team with a job
well done! Great efforts indeed.
N/A
N/A
3/1/2004
OK
No Change
None
General
Gen-Com25
Building
Acoustics
N/A
(General
LEED-EB
Comments)
Although acoustic quality has no specific
designation in any of the current LEED
rating systems, it should be considered
as a desirable feature that improves
quality of life in a building that is being
reused. Of critical importance are the
constraints imposed by an existing
building and the physical manifestations
of structure, envelope, and system that
give an existing building its character.
Because many elemental building
aspects are desirably maintained for
reuse, the means for achieving
appropriate and cost-effective acoustic
performance must be considered.
Indoor Environmental Quality
When assessing indoor
environmental quality,
consideration of acoustic quality
is intertwined with ventilation,
thermal, and lighting design
strategies. Most notably,
acoustic privacy and freedom
from distraction has measurable
effects on user satisfaction and
productivity in buildings. There
are three areas where acoustic
quality is inextricably connected
to building environmental quality:
Thermal: Use of thermal
massing and reduction of
heating and cooling loads often
means sufficient direct exposure
of building occupants to either
the internal building envelope
(i.e., exposed concrete) and/or
the outside. If not carefully
considered, this can also mean
that less sound-absorbing
materials will be used, exposure
to external noise may increase,
and can lead to an
uncomfortable level of noise.
Ventilation: Many of the more
energy-friendly ventilation
systems provide great benefit by
virtue of being very quiet.
owever a high degree of
Acoustic
considerations
should be
incorporated into all
LEED assessment
systems, as all too
often, once the
building is in
operation, acoustic
problems need to be
remediated, costing
time and materials
(not very
sustainable).
Furthermore, this
inclusion would drive
the acoustics market
towards more
sustainable products
and operation.
3/1/2004
Building Acoustics will be considered in a future revision of LEED-
EB
No Change
None
General
Gen-Com26
Scope of
Application of
LEED-EB
N/A
(General
LEED-EB
Comments)
It has been suggested that LEED-EB
should be renamed to LEED-OM to
address the fact that it places such
heavy emphasis on Operating &
Maintenance Procedures and that it is
otherwise confused with many
renovation projects. We recently had a
situation where LEED-NC was accepted
as a standard for new buildings and
LEED-EB as a standard for existing
buildings (regardless of the scope of the
renovation) in a US Government SFO.
This resulted in a very apples-to-
oranges comparison among projects
that submitted proposals using either
system.
Please consider revising to
LEED for Operations and
Maintenance (LEED-OM).
See above.
3/1/2004
Please see response to General Comment 6.
See General Comment 6
See General
Comment 6
General
Gen-Com27
Explain Structure
of LEED-EB
N/A
(General
LEED-EB
Comments)
1. Page 3 "Building Operating
Performance Data" has a
statement about being able to
get initial certification with 3
months of data. I believe this
should be clarified, for example
several of the EA credits call for
12 months of utility bills and
annual data. Does the statement
on page 3 override the 12 month
or annual requirement? Judging
building energy performance
doesn't make sense on 3
months of data, so I assume this
is not the intent. I think each
credit should explicitly say where
it is acceptable to provide 3
months of data for initial
certification. 2. Statement /
description of overall structure of
the credits (e.g. Intent,
Requirement, etc.) and what the
sections are would be helpful
(similar to that used in NC
reference guide.)
3/1/2004
Please see response to General Comment 1. An explanation of
this issue will be included in the LEED-EB introduction.
An explanation of this issue
will be included in the LEED-
EB introduction.
Editorial
General
Gen-Com28
Congratulations
N/A
(General
LEED-EB
Comments)
Hello Mr. Michael Arney, LEED-EB
Committee Chair - Per our telecon on
the subject matter last week, here are
my cursory review comments on the
Draft Document, as requested by
USGBC by the end of March 30, 2004 -
1. Overall, your committee has done an
excellent job in organizing, packaging,
and developing LEED-EB document;
OK
No Change
None
General
Gen-Com29
Good intentions
N/A
(General
LEED-EB
Comments)
Several credits offer points for
developing plans or specifications that
would establish goals to meet the intent
of the credit. This approach has the
potential to give credit to buildings that
have done nothing more than develop a
good intention. While existing buildings
could be recognized for having "good
intentions," it should not be too easy for
them to get these points.
A number of LEED-EB points are awarded for the combination of
(1) having a plan/policy in place and (2) documenting that this
plan or policy has been followed over the performance period.
The combination of established policies that result in actual
performance is essential to reduction of the environmental
footprint associated with the operations and maintenance of
buildings.
No Change
None
General
Gen-Com30
Materials credits
N/A
(General
LEED-EB
Comments)
Existing buildings is designed to 'green'
building upgrades and system
upgrades. Point thresholds used in
LEED for new construction do not make
sense in the context of existing buildings.
Make point thresholds for rapidly
renewable materials, recycled content,
FSC certified wood more stringent.
Do not treat Commercial Interiors and
EB differently, for example the Low
Emitting Materials credit in EB is not
applicable and references CI. The low
emitting materials credit should not
differ from the materials points (recycled
content, local, etc.), which are included
in EB.
The LEED-EB required achievement levels to earn points for the
materials credits are set at appropriate levels for existing
buildings.
No Change
None
General
Gen-Com31
Documentation
N/A
(General
LEED-EB
Comments)
In general, LEED EB needs to be
simplified for building owners/managers
who don’t have enough time to track in
the detail that LEED requires. The depth
of initial documentation is warranted, but
annual re-submittals MUST be made as
easy as possible. In our experience, few
projects make LEED documentation a
priority because it is so burdensome. It is
even more likely that many people will
do annual re-submittals that are also
burdensome. The USGBC must
remember that ‘green’ and LEED are
components of buildings that must be
seen as adding value, rather than being
onerous. If the system is not simplified
and streamlined, particularly with EB
which requires so much continual
documentation, it will not be successful.
For recertification, the filings will consist primarily of performance
data for the performance period. Previously filed materials do not
need to be filed except where these have changed.
No Change
None
General
Gen-Com32
Marketing
materials
N/A
(General
LEED-EB
Comments)
In addition, really good materials must
be created to promote LEED EB.
Simplified overviews of the program to
get building-owner buy in are of utmost
importance.
Marketing materials explaining benefits of LEED-EB certification
have been prepared and are available.
No Change
None
General
Gen-Com33
Second round of
public comment
N/A
(General
LEED-EB
Comments)
I like to thank the EB Committee for all
of its hard work developing this draft.
Existing buildings are very different from
new construction and it has been a
tough nut to crack.
I will begin with a general overview,
followed by credit and credit comments.
Overall, I think the standard still requires
a lot of work before we can take it to
ballot. Just my opinion, but nothing I
see you doing to improve it will help us
avoid a second round of public
comment. Sorry, guys, too much needs
to change from this version before we
can let it go.
A second public comment on substantive changes made to the
LEED-EB draft in response to comments received during the first
public comment round will occur.
No Change
None
General
Gen-Com34
Credit language
is complicated
N/A
(General
LEED-EB
Comments)
My principal issue is that the credit
language tends to be very complicated --
in some cases impenetrable -- and not
user-friendly in many other instances.
“Have in place during the performance
period” is emblematic of this turgid,
bureaucratic language. In several
places, the standard legislates the
requirements through the submittals or
through the technologies and strategies
sections.
Comments on specified points will be addressed for each specific
point where they are raised.
No Change
None
General
Gen-Com35
Plans and
policies
N/A
(General
LEED-EB
Comments)
The reliance on plans and policies, on
top of all the reporting requirements
implies to me a preponderance of paper
or at least many-paged computer
documents that will be very difficult to
evaluate on the USGBC side, not to
mention potentially very time-consuming
on the owner’s side. It also means that
many of the performance benchmarks
are vague or absent.
A number of LEED-EB points are awarded for the combination of
(1) having a plan/policy in place and (2) documenting that this
plan or policy has been followed over the performance period.
The combination of established policies that result in actual
performance is essential to reduction of the environmental
footprint associated with the operations and maintenance of
buildings.
No Change
None
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